Page:United States Statutes at Large Volume 98 Part 1.djvu/619

(ii) a group of 1 or more shareholders (acting in concert)— (I) acquired, during the 1-year period ending on February 1, 1984, at least 10 percent of the out10 > } r: standing stock of the controlled corporation, (II) held at least 10 percent of the outstanding ?>"^eoq '• stock of the common parent on February 1, 1984, lo

98 STAT. 571

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(III) submitted a proposal for distributions of interests in a royalty trust from the common r. parent or the controlled corporation, and (iii) the common parent acquired control of the conK;,o >,. trolled corporation during the 1-year period ending on •;February 1, 1984. (B) DEFINITIONS.—For purposes of this paragraph— (i) The term "common parent" has the meaning given such term by section 1504(a) of the Internal j^ Revenue Code of 1954. , (ii) The term "controlled corporation" means a corporation with respect to which 50 percent or more of the outstanding stock of its common parent is tendered for

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pursuant to a tender offer outstanding on March 7, 1984.

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(iii) The term "subsidiary controlled corporation" ^. means any corporation with respect to which the controlled corporation has control (within the meaning of section 368(c) of such Code) on March.7, 1984.

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Post, p. 577.

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^-' "'^' (6) EXCEPTION FOR CERTAIN DISTRIBUTION OF PARTNERSHIP IN-

TERESTS.—The amendments made by this section shall not apply to any distribution before February 1, 1986, of an interest in a partnership the interests of which were being traded on a national securities exchange on March 7, 1984, if— (A) such interest was owned by the distributing corporation (or any member of an affiliated group within the meaning of section 1504(a) of such Code of which the distrib'• uting corporation was a member) on March 7, 1984, • (B) the distributing corporation (or any such affiliated member) owned more than 80 percent of the interests in such partnership on March 7, 1984, and !<) (C) more than 10 percent of the interests in such partnership was offered for sale to the public during the 1-year period ending on March 7, 1984.

(1) IN GENERAL.—Subparagraph (A) of section 852(b)(4) (relating to loss attributable to capital gain dividend) is amended to read as follows:

26 USC 852.

"(A) Loss ATTRIBUTABLE TO CAPITAL GAIN DIVIDEND.—If—

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"(i) subparagraph (B) or (D) of paragraph (3) provides that any amount with respect to any share is to be treated as long-term capital gain, and "(ii) such share is held by the taxpayer for 6 months or less,